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What is happening?
Effective January 23, 2023, the Fire Safety (England) Regulations 2022 will require all responsible persons of multi-occupied residential buildings in England with a height greater than 11 metres to comply with the following regulations:
All fire doors, including those with automatic closing mechanisms, should be inspected at least once every three months.
All doors leading out to the building's common areas, including those that automatically close, should be inspected at the very least once a year.
Responsible parties in buildings with two or more dwelling units (that share common areas) will also be obligated to disseminate information to tenants about the significance of fire doors to the fire safety of the building.
Why is this being done?
The Grenfell Tower Inquiry's Phase 1 report said, "Fire doors play an important role in preventing or slowing the spread of smoke and toxic gases and keeping buildings well-separated."
The fire doors in Grenfell Tower were not functioning properly due to damage and neglect, as noted by the Inquiry.
It was recommended in the Inquiry (Recommendations 33.29 (a) and (b)) that every owner and manager of a residential building with multiple units immediately inspect all fire doors to ensure compliance with current legislative standards and that regular checks be made to ensure all fire doors are fitted with an effective self-closing device that is in working order.
Also, in Recommendation 33.30, the Inquiry suggested that those responsible for the condition of the entrance doors to individual apartments in high-rise residential buildings with unsafe cladding should be required by law to ensure that these doors conform to current standards.
Before the Fire Safety Act of 2021 was passed, there may have been times when flat front doors were considered during fire safety checks in multi-unit buildings. The Fire Safety Act of 2021 clarifies that doors leading into apartments are subject to the Fire Safety Order, clearing up any doubt about the matter.
The regulations will necessitate that responsible persons in multi-unit dwellings higher than 11m conduct best-effort annual checks of individual unit entrance doors and quarterly checks of common area doors.
Residents will better understand their role in maintaining the safety of the building if they are informed of the significance of fire doors and will be more likely to grant authorised individuals access to their apartment entrances for safety checks if they are told of the importance of these checks.
Present situation
The responsible person's responsibility to implement general fire precautions and their duties under Article 17 of the Fire Safety Order applies to all buildings within the scope of the Fire Safety Order, regardless of height, and are not superseded by the inspections mandated by the regulations (see below).
Those in charge will have to determine how to best interact with residents to gain access to their buildings for the annual door checks. To facilitate access, the responsible party may need to coordinate with residents to set a convenient date.
Access Issues
Flat dwellers should be urged to let trustworthy people check the security of their buildings by opening their front doors. The resident information mandated by these rules can be used in conjunction with other methods of resident participation.
If access is denied, the responsible party should compile evidence to demonstrate that they have made reasonable efforts to fulfil their obligation. This may involve the responsible party writing to the resident to request access.
Minimum requirements for fire door inspections
The minimum requirement is that the responsible person inspects the doors to identify any apparent damage or issues. It should not be necessary to hire a specialist to perform these checks because the responsible person should be able to do so themselves. Several helpful online guides can assist a responsible person in conducting reviews.
A responsible person should think about the following:
If the glazing apertures or air transfer grille of a door have been altered or damaged
If there are any gaps around the door frame and the seals and hinges are fitted adequately that the door closer shuts the door that the door closes correctly around the entire frame that there is no visible damage to the door or door closer (either deliberate or from wear and tear)
Suppose any issues are discovered during these checks. In that case, it may be necessary to conduct more detailed inspections of the doors (or the self-closing device) if any damage is found during the initial assessment. This could entail hiring a specialist.
Fire door inspections in buildings under 11 metres tall
The regulations do not repeal the requirement for a responsible person to implement general fire precautions in any premises covered by the Fire Safety Order, regardless of building height.
The Fire Safety Act 2021 clarified that any residential building containing two or more domestic premises is subject to the Fire Safety Order.
Responsible persons for residential buildings under 11 metres in height are required to instal general fire precautions, which includes ensuring that all fire doors, including flat entrance doors, are capable of providing adequate protection.
Residents in all residential buildings with two or more sets of domestic premises will also be required to receive information on fire doors from responsible persons.
Responsible parties should provide information to residents.
The information provided to residents should emphasise the significance of keeping doors closed, the importance of not tampering with doors and self-closing devices, and the urgency of reporting any faults or damage to doors.
This information will be provided to residents when they move into a multi-family dwelling and annually after that.
Fire door compliance in London.
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